ML20084D042

Motion to Hear Testimony of JW Fischer Out of Turn. Testimony Would Illuminate Certain Aspects of Contention VI-1 Re Margins & Factors of Safety Associated W/Natl Welding Codes.W/Certificate of Svc.Related Correspondence

ML20084D042
Person / Time
Site:	Limerick
Issue date:	04/27/1984
From:	Wetterhahn M CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8405010163
Download: ML20084D042 (5)

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0 REtATED CORRESPONSE 00LKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '84 APR 30 All :13 Before the Atomic Safety and Licensing... Board cECFC' NCnOis'[4 SS /c In the Matter of ) El 1:C"

)

Philadelphia Electric Company ) Docket Nos. 50-352

) 50-353 (Limerick Generating Station, )

Units 1 and 2) )

APPLICANT'S MOTION TO HEAR THE TESTIMONY OF DR. JOHN W. FISCHER OUT OF TURN One member of Applicant's witness panel with regard to Contention VI-1, is Dr. John W. Fischer, Professor of Civil Engineering and Associate Director of the Fritz Engineering Laboratory of Lehigh University. Dr. Fischer's limited purpose in testifying is to discuss margins and factors of safety associated with the various national codes involved in the welding of structures. As previously noted in the

" Transmittal of Applicant's Testimony Relating to Contention VI-1" (April 16, 1984), Professor Fischer is only available to testify on May 10 and 11, 1984. Applicant moves that, for the reasons discussed below, Dr. Fischer's testimony on this limited subject area be postponed to those dates.

Professor Fischer has unique credentials to testify on the subject matter. He played a role in the~ development of welding codes for structures and has extensive practical experience in the field of his testimony. The schedule 8405010163 840427 PDR ADOCK 05000 G

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conflict arises out of the fact that he is Chairman of the Bridges Committee of the American Society of Highway and Transportation Officials whose annual meeting has been scheduled for Burlington, Vermont for the period of May 7 through May 9, 1984. He is scheduled to be delivering two papers during that period and is therefore unavailable to testify. In these circumstances, Applicant asks that the testimony of Dr. Fischer be heard starting on May 10, 1984 at a convenient time whether or not the remainder of Appli-cant's panel has completed testifying. Of course, if the hearing is concluded by that time, Applicant recognizes that his testimony would not be heard.

In the context of other contentions, the Board has expressed an interest in the margins inherent in applicable codes and standards. Applicant believes the testimony of this witness would be extremely helpful to the understanding of certain aspects of Contention VI-1.

Staff has stated that it has no objection to the granting of this motion.

Respectfully submitted, CONNER & WETTERHAHN, P.C.

Mark J. Wetterhahn Counsel for the Applicant April 27, 1984 r - - - , . . , ~. y - -

4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

)

Philadelphia Electric Company ) Docket Nos. 50-352

) 50-353 (Limerick Generating Station, )

Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicant's Motion to Hear the Testimony of Dr. John W. Fischer Out of Turn,"

dated April 27, 1984 in the captioned matter have been served upon the following by deposit in the United States mail this 27th day of April, 1984:

• Lawrence Brenner, Esq. (2) Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Docketing and Service Section

• Dr. Richard F. Cole Office of the Secretary Atomic Safety and U.S. Nuclear Regulatory Licensing Board Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555

• Ann P. Hodgdon, Esq.

Counsel for NRC Staff Office

• Dr. Peter A. Morris of the Executive Atomic Safety and Legal Director Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555

• Hand Delivery

Atomic Safety and Licensing Angus Love, Esq. 107 East Board Panel Main Street Norristown, PA U.S. Nuclear Regulatory 19401 Commission Washington, D.C. 20555 Robert J. Sugarman, Esq.

Sugarman, Denworth &

Philadelphia Electric Company Hellegers ATTN: Edward G. Bauer, Jr. 16th Floor, Center Plaza Vice President & 101 North Broad Street .

General Counsel Philadelphia, PA 19107 2301 Market Street Philadelphia, PA 19101 Director, Pennsylvania Emergency Management Agency

! **Mr. Frank R. Romano Basement, Transportation 61 Forest Avenue and Safety Building Ambler, Pennsylvania 19002 Harrisburg, PA 17120 Mr. Robert L. Anthony Martha W. Bush, Esq.

Friends of the Earth of Kathryn S. Lewis, Esq.

the Delaware Valley City of Philadelphia 106 Vernon Lane, Box 186 Municipal Services Bldg.

Moylan, Pennsylvania 19065 15th and JFK Blvd.

' ^ Philadelphia, PA 19107 Phyllis_Zitzer, Esq. Limerick Ecology Action P.O. Box 761 Spence W. Perry, Esq.

{ 762 Queen Street Associate General Counsel Pottstown, PA 19464 Federal Emergency Management Agency Charles W. Elliott, Esq. 500 C Street, S.W., Rm. 840 Brose and Postwistilo Washington, DC 20472 l

1101 Building lith & Northampton Streets Thomas Gerusky, Director Easton, PA 18042 Bureau of Radiation l Protection

< Zori G. Ferkin, Esq. Department of Environmental l Assistant Counsel- Resources Commonwealth of Pennsylvania 5th Floor, Fulton Bank Bldg.

Governor's Energy Council Third and Locust Streets 1625 N. Front Street Harrisburg, PA 17120 l Harrisburg, PA 17102 Jay M. Gutierrez, Esq.

U.S. Nuclear Regulatory Commission P.O. Box 47 Sanatoga, PA ~19464 i

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• • Federal Express

t James Wiggins Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 47 Sanatoga, PA 19464 Timothy R.S. Campbell Director Department of Emergency ~

Services 14 East Biddle Street West Chester, PA 19380 AA

^

MadW J. Wetterhahn i

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